The appellant, Parwinder Singh Gill, appeared at the First Tier Tribunal (FTT) to appeal a personal liability notice (PLN) totalling £1,781,474.60 for VAT periods 01/15 to 06/19. HMRC argued that the PLN was issued due to deliberate inaccuracies in VAT returns made by PS Gill Construction Ltd (PSGCL) which were attributable to Gill as an officer of the company.

Having heard the evidence from Gill who was represented by Nathaniel Monk, managing partner of TM Sterling Ltd, a tax consultancy firm, the tribunal had one issue to consider, whether Gill had acted deliberately.